The Consumer Federation of America, which spearheaded the formulation of the principles, Consumers Union, the Center for Digital Democracy and Media Access Project also released a comprehensive legal and economic analysis of the increasing problem of concentration in mass media markets.

"Chairman Powell defines his job as promoting variety in the entertainment market," said Mark Cooper, CFA's Director of Research, "but the First Amendment is about ensuring vibrant civic discourse through diversity of viewpoints and vigorous competition between institutions in the gathering and dissemination of news and information."

"This report establishes a firm evidentiary basis for preserving the current rules that set limits on the number and type of media outlets any single entity can own in any local market and across the nation," said Gene Kimmelman, Senior Director of Public Policy and Advocacy for Consumers Union.

"The stakes for the nation are huge," said Jeffrey Chester, Director of the Center for Digital Democracy. "The mass media are the primary means through which citizens gather news and information and ultimately express their opinions."

The 210-page report, entitled Democratic Discourse in the Digital Information Age, demonstrates that the media studies recently published by the FCC are asking the wrong questions because

they look at variety of entertainment when they should be looking at diversity of information,

they worry about number of outlets when strength of journalistic institutions is what matters,

they downplay the key role of concentration of ownership, and

they ignore the size and diversity of the population served by the media.

"Even with their misdirection and numerous methodological biases, the studies fail to support Chairman Powell's claims about widespread overlap between media products," Cooper noted.

Analyzing several previous instances in which ownership limits were relaxed, the paper concludes that the industry behaves according to a simple principle "If you let them, they will merge." The report predicts that repeal or significant modification of media ownership rules will open the floodgates of mergers and acquisitions and will reduce competition and diversity in the media

TV and daily newspapers-in every local market will become highly concentrated, with fewer than four owners per market.

The national total of owners of TV stations and daily newspapers will shrink to as few as 300 owners of TV stations and newspapers.

Most newspapers would be integrated TV stations and lose their independent ability to criticize the electronic media.

"Convergence of communications and mass media in digital networks increases the power of the media and the threat that concentrated control of the media in the hands of a few corporations will destroy the people's First Amendment free speech rights," Chester pointed out.

"Recent public opinion surveys make it clear that the public does not support the FCC's push towards concentrated media markets," Cooper noted. "The public is troubled by the growing concentration of the media and expresses strong support for public interest obligations for both television, the Internet and open communications networks."

Two-thirds of the respondents to public opinion polls think media corporations are already too big and would like to see the mega mergers stopped.

They believe that the mergers raise prices, lower quality and reduce diversity.

They want more reporting on local events and public affairs, which large national corporations are less likely to provide.

"By taking a narrow view of entertainment economics as his primary responsibility," Kimmelman concluded, "Mike Powell is selling short the bold aspiration the Supreme Court laid out for the First Amendment when it declared that the public interest demands the widest possible dissemination of information from diverse and antagonistic sources."